Author: rogercaiazza

This is part of my continuing coverage of the New York State Energy Plan.  On July 23, 2025, the Draft Energy Plan was released for comment.  There is every indication that the Hochul Administration is just going through the motions of a stakeholder process like they did with the Scoping Plan.  This is too important to not do correctly.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Energy Plan Overview

According to the New York State Energy Plan website (Accessed 3/16/25):

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

I have provided more background information and a list of previous articles on my Energy Plan page. 

Responsibility for implementing the Energy Plan as well as all the Climate Act programs lies with the New York State Energy Research & Development Authority (NYSERDA).  Over my career I have seen an ever-increasing level of political influence on NYSERDA’s research priorities and, more recently, the research results. This post describes my concerns relative to the energy plan stakeholder process.

Stakeholder Promise and Reality

The July 23, 2025 meeting presentations mentioned public participation multiple times.  The following slide (Figure 1) described the process for Draft Energy Plan involvement.  The Draft Energy Plan website has links for submitting written comments and participation in public hearings.  However, indications are that this is just going through the motions.  The public hearings are only two hours long and speakers are limited to two minutes.  That is not nearly enough time to provide anything meaningful.

Figure 1: Public Review Process Description in July 23, 2025 Meeting Presentation.

I signed up to make a statement soon after the hearing notice was announced.  This article documents the comments I plant to provide about the public comment process.

Concern

My first post describing the Draft Energy Plan mentioned two critical requirements for a satisfactory Energy Plan.  Defining metrics for affordability, reliability, and acceptable environmental impacts should be a primary component of the Energy Plan.  A transparent and comprehensive stakeholder process is also needed for credibility.

My worries that NYSERDA treatment of public input in the Energy Plan stakeholder process will mimic the Scoping Plan process have been a consistent theme in all my articles on the Energy Plan process.  I think that NYSERDA is following the same script where the numbers were tortured to provide the desired analysis then tied up into a pretty package.  Now they will go through the motions of accepting public input but will not respond to comments submitted.  The problem is that many of the same inconsistencies and identified problems that did not get addressed in the draft Scoping Plan are present in the draft Energy Plan.  This is unacceptable.

Example 1

The “Retirement Input” tab in the Pathways Analysis Technical Supplement: Key Drivers and Outputs spreadsheet is shown in Figure 2.  It states that the expected lifetimes for wind, solar, and storage are indefinite.  Most of the existing wind and solar and all of the existing storage will have to be replaced by 2040.  This is an absurd assumption.

Figure 2: Retirement Inputs Table

On June 16, 2022 I submitted a Comment on Retirement Input Assumptions used in the Draft Scoping Plan.

In what appears to be an egregious attempt to reduce the published costs of wind, solar, and battery storage the Integration Analysis assumes that the expected lifetimes of those technologies is indefinite.  As a result, units are assumed to remain online throughout the study period and no costs for replacements between now and 2050 are included.  However. that is a poor assumption because it is totally unreasonable to expect that, for example, the existing land-based resources will still be in operation in 2050.

I estimated the potential impact of this assumption.  Using an indefinite retirement date for these resources underestimates the total builds needed for 2050.  For land-based wind between 3,814 MW and 4,600 MW are not included and for offshore wind between 6,200 and 6,600 MW are not included.  The amount of solar not included ranges between 22,639 MW and 19,983 MW.  Finally, for battery storage between 10,713 MW and 12,207 MW of additional resources will be need to be developed to meet the 2050 projected value. 

The Draft Energy Plan only covers the next 15 years to 2040 so these projections are not completely compatible.  Nonetheless, this is still a uncontestably incorrect assumption.  This error will cause an underestimate of the costs to comply with the Climate Act 2040 mandates.  It is a matter of credibility if it is not acknowledged.

I could go on to provide other examples of issues that I raised in the Draft Scoping Plan that are present in the Draft Energy Plan.  There is no point in bothering to document these issues if there is no commitment to respond to all comments submitted.

Example 2

I have always been concerned about differences between the NYSERDA analyses and the work of the New York Independent System Operator (NYISO).  The NYISO mission is “Ensure power system reliability and competitive markets for NY in a clean energy future”.  As part of that responsibility NYISO performed in-depth analyses of power system data and made projections showing estimated changes as a result of the Climate Act.  There are significant differences (Table 1) between the NYISO projections of future generating resource capacity and the NYSERA sponsored analyses that have never been reconciled in an open and transparent public forum.

Table 1: Comparison of 2040 Fuel Mix Capacity (MW) Projections by NYISO and NYSERDA

I am particularly concerned about the capacity differences for the Zero-Carbon Firm or Dispatchable Emissions-Free Resource.  NYISO projects a significantly higher necessary capacity.  There are fundamental viability issues associated with DEFR and it appears that the two modeling approaches are treating the resource differently.  It is critically important that the differences get resolved.  Failure to do so goes beyond a credibility issue associated with the process.  .If this is not resolved there could be reliability consequences and the potential for catastrophic blackouts. 

There is another aspect of the differences between NYSERDA and NYISO  The NYISO analyses have never revealed their cost estimates for the transition.  That information would either provide reassurance that NYSERDA electric system transition estimates are supportable or suggest they need to be improved.

Recommendation

I believe that the stakeholder process for the Climate Act is broken because NYSERDA and other state agencies treat it as an obligation and not an opportunity.  NYSERDA claims that there was “robust public input” during the draft Scoping Plan process that “included 11 public hearings across the State and more than 35,000 written comments” that supposedly were read, summarized, and presented to the Climate Action Council.  The problem is that Agency staff screened the comments for the Climate Action Council and there is no publicly available documentation of their work.  They only presented generalities at meetings and did not summarize specific comments.  I am convinced that any comments that questioned the narrative espoused by Climate Act proponents were ignored and there is no evidence that I am wrong.

I recently found an example of how a stakeholder process should work.  The Santa Clara County Rapid Transit Development Project includes a master plan for transportation for Silicon Valley.  An interview with the founding manager notes: “Part of the plan is a four-year public stakeholder review process.  In the reviews, if the public came up with good ideas, the ideas went into the plan.  If an idea wasn’t good, we had the responsibility of explaining why” from California’s High-Speed Rail Visionary Bill Buchanan, Trains, Volume 85, No. 1, January 2025, pages 30-37.  The process also included public outreach meetings that included the opportunity to ask questions.

A robust public input process includes public outreach.  The Draft Energy Plan was announced after a series of Planning Board meetings earlier this year.  There hasn’t been any opportunity for stakeholders to ask questions about the assumptions and methodologies used.  If the State was serious about considering public input for an energy plan that affects every New Yorker, then they would hold a series of meetings to cover specific technical topics.  A stakeholder process that does not allow for interaction between stakeholders and NYSERDA staff is nearly useless.

In my opinion, NYSERDA should provide a public response to all the substantive comments made regarding the Draft Energy Plan.  A publicly available summary describing specific comments, responses to the issues raised by comments and the recommendation for resolution in the final Energy Plan should be provided to the Energy Planning Board, the Public Service Commission and the public.  If the State is to have any credibility regarding their Energy plan stakeholder process, then they must provide documentation showing that all the comments were considered and addressed.

Conclusion

My biggest Energy Plan concern is whether the Hochul Administration will use the Energy Plan process as an opportunity to consider the implications of the observed transition so far and if the advice of stakeholders in its stakeholder process will be treated as an opportunity to improve the transition.  Earl indications suggest that they are only going through the motions with no attempt to meaningfully engage with any comments inconsistent with the narrative

I am very frustrated with the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition because the reality is that there are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to proceed.  This article describes reasons to pause implementation.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Dennis Higgins on the Grid of the Future

Were it not for my overloaded schedule I would prepare a post devoted to this submittal by Dennis Higgins in the Grid of Future Case 24-E-0165 proceeding. Higgins describes five overarching issues that must be resolved for the Climate Act transition to be successful.  The following are selected quotes from his filing.

1. The North American Energy Reliability Corporation (NERC) lists five risks to the bulk power system. Risk #1 is a bad energy plan and risk #2 are changes made to the grid to implement a bad plan.  A ‘renewable’ based grid will need a whole new transmission structure – bigger than the current grid — which someone will have to pay for. It will need full-capacity dispatchable backup and expensive battery energy storage systems. Any wind, solar, and energy storage resources installed today will need replacement by 2050. New York may not be able to shutter significant fossil-fuel power plants but may, rather, be obliged to build more. California – two decades ahead of New York in pursuit of solar and wind — has extended the operations of three gas power plants until 2026 to maintain energy reliability and affordable rates.
2. Academic studies as well as empirical evidence do not support claims that wind and solar will prove economical or reliable. Recent studies suggest wind may raise surface temperatures offsetting any carbon-cutting advantage in the technology.
3. NERC warns that inverter based resources can undermine grid reliability. “Since 2016, NERC has analyzed numerous major events totaling more than 15,000 MW of unexpected generation reduction. These major events were not predicted through current planning processes. Furthermore, NERC studies were not able to replicate the system and resource behavior that occurred during the events, indicating systemic deficiencies in industry’s ability to accurately represent the performance of IBRs and study the effects of IBR on the bulk power system (BPS).”
4. Sweden, and others, do not see intermittent resources reducing costs or adding reliability.  Sweden provides a cautionary tale of what reliance on, and accommodations for, wind power can mean. In fact, over a megawatt of dispatchable generation is necessary for every megawatt of renewable added to the grid: “a 1% percent increase in the share of fast-reacting fossil generation capacity is associated with a 0.88% percent increase in renewable”
5. NYISO has repeatedly warned of reliability issues. “As traditional fossil-fueled generation deactivates in response to decarbonization goals and tighter emissions regulations, reliability margins on the grid are eroding. Further, the remaining fossil-fueled generation fleet, which provides many of the essential reliability services to the grid, is increasingly made up of aging resources, raising further concerns about grid reliability. Strong reliability margins enable the grid to meet peak demand, respond to sudden disturbances, and avoid outages. They also support the grid’s ability to respond to risks associated with extreme weather conditions. As these margins narrow, consumers face greater risk of outages if the resources needed for reliability are unavailable due to policy mandates or failures associated with aging equipment.

Higgins did a great job compiling these cautionary tales.  Anyone of these should be sufficient reason to pause Climate Act implementation.

Lessons from California

JohnS has compiled a comprehensive evaluation of the status of the net zero transition in California.  As he points out, if an electric system transition to one dependent upon solar and wind can work somewhere, then this is the ideal state: “The state’s abundant sunshine, clear skies, and deserts near major population centers create perfect conditions for solar power.”

Spoiler alert – it is not working.  At the current rate of emissions decline California will reach zero emissions in 145 years.  He concludes: “Without an immediate and abrupt policy shift, California is not on a path to achieving its 2045 emissions goal. It’s impossible to predict how close they will get; it all depends on how much economic pain they can endure and how many ecosystems they are willing to sacrifice.” 

He also describes a lesson for New York:

A key lesson for other regions is that solar power is a difficult path, even for a wealthy American state with sunny weather and deserts close to big cities. It will be even more difficult in other regions. For instance, New York State has a solar capacity factor of 19.5%, which means the cost of solar power there will be about 1.5 times higher than in California. And without deserts, finding locations for solar farms will be more difficult. Colder climates also have more severe heating needs. Tripling annual heating costs by switching to heat pumps will be more than a tough sell.

There is an enormous amount of relevant information in this article.  California’s transition is ahead of New York.  None of the lessons learned in California suggest the New York will be able to improve upon their efforts.  This just cannot end well.

Iberian Peninsula Blackout

Two recent posts at the Watt-Logic blog describe the blackout this spring on the Iberian peninsula  that affected Spain, Portugal, and France.  The first article looked at the physics of power grids and the general behavior of both synchronous generation (gas, hydro and nuclear) and inverter-based generation (wind, solar and batteries).   It includes a good description of some of the details of the electric system that no one who was involved with the development of the Climate Act law understood.  If they had any inkling of the complexity of the system they would not have been so quick to go for a zero-emissions electric system reliant on wind, solar, and storage.  More importantly it explains why the proposed changes are so risky.  The second post addressed what we know about the Iberian blackout. He explains that voltage control and reactive power limitations of the Spanish grid caused by over-reliance on wind and solar weakened the grid to the point where “single faulty solar inverter” caused the blackout.

This raises an important issue.  We are told that the zero-emissions future New York electric system will be more resilient.  Am I the only one who is worried that the Chinese ‘kill switches’ found in equipment at US solar firms could trigger a single solar inverter to cause a blackout?  The fact that a single inverter could cause a blackout is not a sign of a resilient system.

Lessons from Down Under

The New Zealand Energy website described how the effects of a drop off in wind production caused a “wild ride” in their electric network.  It concluded that more accurate weather forecasting is needed to prevent problems like this causing a reliability issue.  The author goes on to describe the technology needed to respond to a weather forecast warning that a drop off in production is coming:

More backup and more complex control systems are required. This is exactly what Joesph Tainter described as the diminishing returns on complexity in his book “The Collapse of Complex Societies”.

It is very easy for proponents to claim that there are solutions to the many identified problems.  They do not acknowledge the complexity challenge however.

A second article from the other side of the equator is out of Australia.  Rafe Champion explains that the issues described above have led to the situation where the jurisdictions still hell bent on a transition away from fossil fuels have not caught on to the reality that “We have already gone as far as we can go in that direction with existing storage technology. The combination of wind droughts and the lack of feasible grid-scale battery storage makes the green energy transition impossible.” He reiterates the themes of the articles described here and I must say i agree that the transition is impossible.

Conclusion
There will be an inevitable clash between reality and political aspirations. The reasons described here underline the importance of a pause to consider New York’s Climate Act implementation.

This is part of my continuing coverage of the New York State Energy Plan.  After a series of Energy Planning Board meetings this year, on July 23, 2025, the Draft Energy Plan was released for comment.  While there are some indications that reality is dawning on the Hochul Administration, the meetings, the description of the document, and my brief review of the document, there are still troubling aspects of this process.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Energy Plan Overview

According to the New York State Energy Plan website (Accessed 3/16/25):

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

Responsibility for implementing the Energy Plan as well as all the Climate Act programs lies with the New York State Energy Research & Development Authority (NYSERDA).  Over my career I have seen an ever-increasing level of political influence on the research priorities and, more recently, the research results.  If something that could embarrass the administration manages to get funded, the results get buried if they don’t fit the narrative.  This bias was blatantly obvious during the development of the Scoping Plan and it evident here too.

I have provided more background information and a list of previous articles on my Energy Plan page.  My biggest concerns are whether the Hochul Administration will use the Energy Plan process as an opportunity to consider the implications of the observed transition so far and if the advice of stakeholders in its stakeholder process will be treated as an opportunity to improve the transition or an obligation with no attempt to meaningfully engage with any comments inconsistent with the narrative

July 23, 2025 Board Meeting

The materials for the meeting include the following:

Meeting Materials

• Meeting Notice [PDF] (Updated July 17, 2025)
• Draft Meeting Minutes (June 25, 2025 Meeting) [PDF]
• Resolution 14 [PDF]
• Resolution 15 [PDF]

Presentations

• Board Meeting Presentation [PDF]

Draft State Energy Plan

Draft Plan under review by the State Energy Planning Board:

Volume I: Summary for Policymakers [PDF]

Volume II: Topical Chapters [PDF]

Volume II: Analysis Chapters [PDF]

Transmission and Distribution Systems Reliability Study [PDF]

Data Annexes:

• Pathways Analysis Technical Supplement: Inputs and Assumptions [XLSX]
• Pathways Analysis Technical Supplement: Key Drivers and Outputs [XLSX]
• Business Energy Intensity Data Annex [XLSX]
• Energy Affordability Outputs and Input Data [XLSX]
• Public Health Impacts Analysis Data Annex [XLSX]

The Draft Energy Plan documents will be updated to remove the “under consideration” caveats.  I will post articles on details of the meeting later.

Initial Impression

Yesterday’s meeting was a vivid reminder that everything associated with the Climate Act is politically motivated.  It was a political theater from start to end.  They pretended that the Board could provide meaningful comment that might prevent the release of the draft plan but the schedule for hearings and end date for submitting comments was spelled out in all the documents.  With very few exceptions, everything was scripted including the transition between speakers.  After presentations, there were very few questions.  Questions would require going off the script.  During the discussion about whether to release the Draft Energy Plan the responses by board members were scripted too. 

The NYISO representative commented that his organization had been working with NYSERDA.  I got the impression from the commentary and some of the findings mentioned that outside experts have been involved.  While that is encouraging, it remains to be seen how the process will acknowledge and reconcile differences of opinion. 

Affordability

There were numerous references to affordability in the meeting presentation.  I asked my new best friend, Perplexity AI, how many?  I acknowledge the use of Perplexity (https://www.perplexity.ai/) to generate the following summary.

The NYS Energy Plan presentation contains numerous references to affordability, emphasizing its importance throughout. Based on a detailed review of the full presentation text, here is the count and context for the most relevant references:

• The word “affordable” and its variants (such as “affordability”) appear at least 28 times in the presentation.
• References span across core planning goals, specific program actions, sector recommendations, and equity discussions.

Key references by section include:

• Planning Goals and Principles: Affordability is listed as a guiding principle, alongside reliability, equity, and environmental health (slides 75-76, 79-80).
• Program Actions: The Energy Affordability Policy and bill discount programs for lower-income and below-median-income customers are called out specifically (slide 7, 43).
• Sector Strategies: Explaining the goal of affordable zero-emission vehicles and affordable, reliable transit (slides 25, 27-28).
• DAC and Equity: Additional references address minimizing costs for electric ratepayers, reducing disproportionate energy burdens (slides 29, 34, 80, 43).

Summary: The presentation repeatedly highlights affordability as a defining priority for New York’s energy transition—both as a policy goal and via specific programs, especially for low- and moderate-income and disadvantaged communities.

I am sure that the Draft Energy Plan will also emphasize affordability and reliability.  For example, the Summary for Policymakers “pending Board consideration” released  at the meeting says the Energy Plan will be “Advancing abundant, reliable, affordable, and clean energy for New York”.

This is a controversial topic for me.  Until such time that those criteria are defined, talking about affordability is nothing more than a political slogan.  I am going to comment that it is necessary to establish specific affordability, reliability, and environmental impact criteria, set up a tracking mechanism for each, and formulate a mandatory course of action when the criteria are exceeded for the Hochul Administration to have any credibility regarding these key conditions.

Going Forward

A common refrain during the discussion of the release of the Energy Plan was the importance of stakeholder involvement.  This is also a controversial topic for me.  In a matter as complex as the New York energy system, there will be differing opinions about substantive aspects of the different components of the energy system.  The only way for the development process to be credible is for stakeholder comments to be documented and the rationale for how controversies were resolved explained so that when the Energy Planning Board votes to approve it, they will have all the information.

The Climate Act implementation process was not a model to follow.  The differences of opinion between stakeholders and NYSERDA during the Scoping Plan process were not documented.  During the Energy Plan presentations, there were references when speakers implied surprise that the results to date did not comport with the expectations of the analysis performed for the Scoping Plan.  In more than one instance, they referred to something that I know was brought up and ignored during the Scoping Plan stakeholder process.  I cannot recommend strongly enough that this process should respond to all comments and reconcile any differences between NYSERDA and NYISO electric grid projections in a clear and transparent manner.

Politics

Unfortunately, my recommendations flounder on the political reality of New York.  The Democratic Party controls the New York Assembly and Senate, and the Governor is a Democrat.  The Energy Planning Board membership consists of ten agency heads, appointees of the Governor, Speaker of the Assembly, President of the Senate, and Presiding Officer of the New York State Independent System Operator (NYISO).  Of the fourteen members only two have technical energy backgrounds.   All decisions will be decided based on political considerations.  Given the fact that the politicians got us into this mess, I have little hope that they will willingly get us onto a pragmatic path based on reality.

Conclusion

I am encouraged that the Hochul Administration has finally realized that the Climate Act schedule and ambition are impossible to meet.  The presentations at this meeting are consistent with that epiphany.  It is not clear how they intend to reconcile the problems that introduces.

In my opinion, there are two critical requirements for a satisfactory Energy Plan.  Defining metrics for affordability, reliability, and acceptable environmental impacts should be a primary component of the Energy Plan.  A transparent and comprehensive stakeholder process is needed for credibility. I do not expect that my concerns will be addressed.

This is part of my continuing coverage of the New York State Energy Plan.  Previous articles described the Pathways Analysis that is being used to project energy scenarios for the draft energy plan and the modeling scenarios used in the Pathways Analysis.  This is the second part of my description of the economywide results.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Energy Plan Overview

According to the New York State Energy Plan website (Accessed 3/16/25):

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

I have provided more background information and a list of previous articles on my Energy Plan page.  My biggest concerns are whether the Hochul Administration will use the Energy Plan process as an opportunity to consider the implications of the observed transition so far and if the advice of stakeholders in its stakeholder process will be treated as an opportunity to improve the transition or an obligation with no attempt to meaningfully engage with any comments inconsistent with the narrative

June 25, 2025 Board Meeting

The materials for the meeting include the following:

• Meeting Notice [PDF]
• Board Meeting Presentation [PDF]
• Board Meeting Recording Meeting Recording 

I have included links to the locations of the video in the following descriptions.  Also note that a transcript of the presentations is included at the meeting recording video platform.  There is a nice feature for this video.  If you set auto scroll on, then you can follow the presentation transcript.  All quotes below come from that transcript.

I previously summarized this meeting’s presentations that described the analyses conducted for the State Energy Plan, the modeling approach, and described the electricity topic area. This article describes the rest of the economywide results started in the previous post.

Economywide Results

Nick Patane, Assistant Director for policy analysis at NYSERDA, presented the preliminary economywide results from the modeling analyses.  This article starts at his presentation description of the gas system findings.

Figure 1 describes the projected changes in the gas system infrastructure.  The description notes:

• The gas system remains a significant energy delivery resource in all cases over the study period which will require continued investment for safe and reliable provision
• In the No Action case, new construction and fuel switching from oil and electric resistance would lead to gas system expansion
• All electric new construction and building electrification programs show potential to stem near term statewide customer growth in Current Policies and Additional Action cases, with impacts felt more fully in the later period
• Utility Long Term Plans suggests a range of future customer counts, with significant regional variability
• The strategic use of hybrid heating to minimize electric peaks in Net Zero B yields a larger gas network. However, each customer would need to use less gas to preserve the economywide emissions limit

Note that there is a lot of uncertainty.  The area shaded in blue covers the range of projections from the long-term plans submitted by the utilities.  The “Net Zero” scenarios include pathways designed to reach Climate Act goals and indicate the challenge of the transition.  It is all well and good to show 20% of the gas customers are converted in ten years but it is not clear how that could be achieved.  Furthermore, there is another magical, wishful thinking solution in the “Net Zero B” scenario.  This scenario is included to reduce electric load during the winter peak when electric load peaks.  However, expecting that “each customer would need to use less gas to preserve the economywide emissions limit” overall and not just during system peaks is unlikely simply because heating with natural gas is cheaper than heating with heat pumps.

Figure 1: Gas System Infrastructure

The graph of gas system consumption (Figure 2) is like the gas system customer graph.  The shapes of the lines and shaded area are similar.  The description states:

• In combination, statewide Residential and Commercial consumption declines across the cases with improved energy efficiency and electrification
• Utility Long Term Plans suggest a range of potential consumption scenarios, with regional variability
• Regional variation and peak day needs could still require local gas system investment
• The Net Zero cases see transformational consumption decline with accelerated building electrification and shell adoption

In my opinion, when NYSERDA projects a “transformational consumption decline” it is not enough to say that it can be achieved.  It is necessary to prove it.  Why will gas customers be willing to change their consumption.  What is in it for them?  In my personal experience, I looked into a heat pump but found that it could not resolve a heating problem in my home.  Furthermore, in my experience, we have never had a gas outage but have lived through two extended electric blackouts.  During the ice storm outage, we relied upon natural gas, for heating, cooking, and hot water.  That loss of resiliency is a huge advantage for natural gas.  What is in it for me and many others to convert to an all-electric home?

Figure 2: Gas system consumption

Patane described the economywide emissions graph in Figure 3.  He pointed out that “emissions are currently 9.4% below the 1990 statewide emission limit baseline, and 20% below 2005 statewide emission levels” but did not acknowledge that those changes were due to reductions in the electric and industrial sectors.  That is important because there are very few future reductions available from those sectors. 

In the future the presentation claims “Major drivers of carbon reduction across all cases include transportation electrification, device efficiency improvements, and building shell improvements”.  It is magical, wishful thinking to presume that the reductions needed can be achieved with those drivers.  Blithely stating that “NY clean energy policies lead to further carbon reduction in CP/AA including: renewables deployment, more aggressive building/transportation electrification, and improved building codes” without a feasibility analysis is misleading at best. 

Note that they admit that the  2030 40% reduction in emissions target will not be met until 2034 at best but in the core program scenarios not until 2036.  The last bullet, “While there is significant uncertainty, this progress is threatened by recent federal action but strengthened by state action such as the recent $1 billion decarbonization commitment”, is more slogan than substance. 

Figure 3: Climate Act Economywide Emissions

The presentation also included a similar emission reduction graph but used Intergovernmental Panel on Climate Change (IPCC) accounting.  As part of their irrational vilification of natural gas, the Climate Act authors included a novel emissions accounting system that makes it more difficult to achieve the Climate Act targets.  These results are consistent with everyone else.  The bullets for Figure 4, Economywide emissions – IPCC accounting state:

• When applying the conventional format for governmental accounting, most recently reported emissions were 23% percent below the 1990 statewide emission limit baseline
• Current Policies are within 2 MMT of 40% net reduction by 2030, Additional Action and Net Zero cases achieve 40% reduction by 2030

I am not sure why this is included unless NYSERDA is hinting that the Climate Act should be amended to use the greenhouse gas accounting system everybody else uses.  That would be logical but when this idea was floated a couple of years ago the climate activists who are the most vocal proponents of the Climate Act had a tantrum, and the idea was withdrawn.

Figure 4: Economywide emissions – IPCC accounting

The remainder of Patane’s presentation discussed takeaways. 

The near term (2030) takeaway infrastructure story description states:

• Energy system is evolving in meaningful ways – new loads causing system growth, replacement of aging stock leading to improved efficiency, some native adoption of technologies is already underway
• State actions are helping to accelerate this evolution – major drivers of change include:
  • Clean electricity progress, such as 6 gigawatts of distributed solar, completion of South Fork Wind, 1 gigawatt Champlain Hudson Power Express transmission line for new hydropower import along with Empire Wind 1 and Sunrise Wind under construction, and contracting for 10 gigawatts of large- scale renewable energy projects
  • Transportation initiatives
  • All electric new construction, advanced building codes, and heat pump and efficiency programs
  • $1 billion decarbonization commitment by New York State in 2025
• Incremental progress by 2030 is muted as it will take time for effects to translate into stock transformation

Those takeaways do not mean much without a feasibility analysis that addresses costs, schedule, and uncertainty.  My concerns are exacerbated when the long term (2040) infrastructure story is presented:

Long term (2040) infrastructure Current Policies and Additional Action

•            The impacts of existing policies will be felt more fully over time. By 2040,17-24% of the residential heating stock is heat pumps, and 53-59% of the LDV stock is ZEV

•            A significant transformation of the energy system occurs in both Current Policies and Additional Action

•            By 2040, electric loads increase 23-26% to 198-202TWh and peaks increase 22-23% to 37 GW

•            Gas consumption in buildings declines 16-22% when compared to 2025, but the gas system remains a crucial energy delivery system across all cases and regional variation and peak day needs could require new gas system infrastructure

•            Final energy served by electricity increases from 19% in 2025 to 28-29% in 2040, and final energy served by direct fossil fuel consumption decreases from 78% in 2025 to 63-67% in 2040

•            A significant scale up of renewables deployment is needed to achieve 0x40, which is threatened by economic and emerging federal policy challenges

I cannot overemphasize the enormous difference between wishful thinking in the Pathways Analysis modeling and a feasibility analysis.  Is a “significant transformation” possible or is it only a figment of modeling wishful thinking?  For example, they claim that over half the vehicles in use in 2040 will be zero emissions and I predict that will be true when pigs fly.  The scope of changes to personal choice is enormous but cannot be included in the modeling. In the real world, “Economic and emerging federal policy challenges” are existential threats to the Climate Act transition.

The next set of takeaways begrudgingly acknowledges my concerns. 

Emissions Outlook: Navigating External Uncertainties

•            New York State’s existing policies are establishing a foundation for economywide emissions reductions, with notable progress in power generation, transportation, and buildings

•            However, progress has been impacted by factors including disruptions caused by the COVID-19 pandemic and subsequent inflation and supply chain disruptions and global events, such as the energy supply and price impacts resulting from the Russian invasion of Ukraine

•            In addition, evolving federal policies and tariffs introduce uncertainty into the state’s near-term emissions trajectory

However, no path forward to incorporate them was proposed. 

The final takeaways are critical.   In the long-term “Timelines to achieve a 40% reduction in emissions continue to be influenced by external shifts”.  New York cannot control those external shifts so now what.  The bullet “Under the current set of assumptions the planning scenarios will hit 40% reduction as soon as 2036” conveniently ignores the fact that the target is 2030.  The final takeaway “Achieving the long-term net-zero economywide emissions goal by 2050 will likely necessitate substantial incremental efforts beyond what existing policies currently envision.”  The feasibility of the existing policies has never been proven, and the costs have not been acknowledged. 

Discussion

After this presentation, Doreen Harris provided her thoughts.  I think responding to her claims is a good way to discuss the findings.  Her remarks included the following:

I’d say that when we think about planning, I appreciate the fact that the planning scenarios that Nick presented today factor in multiple goals in a realistic way for each sector in the energy system. And I think that’s something that’s very important for us as we are planning in the long term is that this uncertainty requires, multiple scenarios to really, ensure that we’re meeting this affordable, reliable, clean, resilient grid of the future, given that uncertainty.

This encapsulates my fundamental issue with the NYSERDA Pathways Analysis.  The modeling demonstrated how different strategies could affect the energy system.  However, modeling is not a feasibility analysis that addresses whether the grid of the future will be affordable, reliable, clean,, and resilient.  Worse the Hochul Administration has never defined acceptable affordability, reliability, and resilience.  Without defining those terms and evaluating the feasibility of meeting the criteria established, “affordable, reliable, clean, resilient grid of the future” is just a slogan.

But I think the insight into a range of possible energy pathways helps us to develop strategies that allow us to stay adaptable.  And although we will be making progress, of course, toward our policy objectives, that adaptability, I think, will be quite central, to our longer term needs.

Not hard to interpret this as meaning we are going to have to change things going forward.

And as mentioned earlier, we know we face challenges. These are challenges that the Climate Action Council did perhaps not foresee in twenty nineteen and, the subsequent years as we advanced the scoping plan. But importantly and perhaps in a dynamic way, our ability to bring new renewable generation online may continue to be affected by actions at the federal level. So this is something that may evolve as this year develops and something that is hugely, significant relative to the other issues that we’re describing.

Under her watch, NYSERDA ignored stakeholder comments that raised these challenges.  Now she acts surprised.  If this process is the same as the Scoping Plan process the result will be similar.

But also with respect to the analysis, it shows us that reliability needs may require the maintenance or repowering of natural gas generating units in the twenty thirties and beyond. And this is where I had wanted to highlight the consistency of this analysis with the power trends reports that that Rich just, mentioned earlier today, where we see a call for repowering both renewable and combustion generating units in that time frame.

The NYISO has been repeating their reliability concerns since before the Climate Act was passed.  Her staff dismissed differences in the modeling as not significant.  Now we see that the experts were right all along.

However, even so, even with these challenges, this analysis also shows us we can continue to make progress toward a clean energy economy.  So even in the scenario where we experienced significantly reduced build rates, I want to highlight the fact that renewable generation could increase seventy percent between 2025 and 2035.

There still is no recognition that building as much renewable generation as possible as quickly as possible might be a false solution. 

And while electricity use is expected to grow in part from economic development and electrification of transport and home heating, all major fuels that New York uses today, including natural gas and petroleum fuels, will continue to meaningfully contribute to our energy mix through 2040.

I am sure every environmental organization in the state are plotting how they can throw another tantrum to prevent any relaxation of the 2040 goals. The question is whether the Hochul Administration will finally become the adults in the room and say sorry.

So, in summary, this assessment demonstrates that even as we make progress, it is critically important to continue investment in all fuel systems, a diverse set of fuel systems to ensure safe and reliable provision of energy services for all New Yorkers.

All I can say is prove how your assessment will work, respond to all comments this time, and reconcile any differences between NYSERDA and NYISO electric grid projections.

Conclusion

I am encouraged that the Hochul Administration has finally realized that the Climate Act schedule and ambition are impossible to meet.  The presentations at this meeting are consistent with that epiphany. 

On the agenda for the next meeting is to discuss whether the draft energy plan will be released.  Stay tuned.

Note: This post was updated on 7/22/25 to note that the “Limited Building Rate Scenario” projects a zero-emissions grid in 2045, five years later than the Climate Act target. 

This is part of my continuing coverage of the New York State Energy Plan.  My intent is to describe most of the sections of the June 25, 2025, meeting presentation.  As part of my attempt to reduce the size of my articles I will focus this article on a portion of the modeling results with a follow up post with the rest.  Previous articles described the Pathways Analysis that is being used to project energy scenarios for the draft energy plan and the modeling scenarios used in the Pathways Analysis.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Energy Plan Overview

According to the New York State Energy Plan website (Accessed 3/16/25):

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

I have provided more background information and a list of previous articles on my Energy Plan page.  My biggest concerns are whether the Hochul Administration will use the Energy Plan process as an opportunity to consider the implications of the observed transition so far and if the advice of stakeholders in its stakeholder process will be treated as an opportunity to improve the transition or as an obligation with no attempt to meaningfully engage with any comments inconsistent with the narrative

June 25, 2025 Board Meeting

The materials for the meeting include the following:

• Meeting Notice [PDF]
• Board Meeting Presentation [PDF]
• Board Meeting Recording Meeting Recording 

I have included links to the locations of the video in the following descriptions.  Also note that a transcript of the presentations is included at the meeting recording video platform.  There is a nice feature for this video.  If you set auto scroll on, then you can follow the presentation transcript.  All quotes below come from that transcript.

I previously summarized this meeting’s presentations that described the analyses conducted for the State Energy Plan, the modeling approach, and described the electricity topic area. This article will describe the load projections and electric sector’s economywide results.

Economywide Results

Nick Patane, Assistant Director for policy analysis at NYSERDA presented the preliminary economywide results from the modeling analyses.  This modeling analysis is consistent with the Integration Analysis in the Scoping Plan and the New York Independent System Operator (NYISO) projections.  They all expect significant increases in total and peak electric loads due to electrification of buildings and transportation.  There need to be transformational changes to all sectors to meet the Climate Act goals.

Figure 1 graphs the annual load projections.  The presentation slide states:

• Loads grow in all cases over the study period, driven especially by new large loads (+16 TWh) and to various extents vehicle electrification
• Vehicle electrification drives significant additional load growth (+14-17 TWh) in Current Policies and Additional Action
• Building efficiency plays an important role in offsetting building electrification load growth in Current Policies and Additional Action, underscoring the importance of these investments The Net Zero cases see the greatest load growth driven by significant additional building and industrial electrification which would require a transformational infrastructure buildout

In my previous posts I pointed out that the Pathways Analysis scenario “Current Policies” includes programs that are necessary to meet Climate Act targets.  I expect that when NYSERDA presents costs they will present them relative to current policies rather than to “no action”.  If added loads are proportional to costs, then this graph shows that approach will underestimate total consumer costs.

Figure 1: Annual Loads

Figure 2 describes the annual peak load.  The presentation slide states:

• New large loads (+2.5 GW) and vehicle electrification to varying degrees will drive peak load growth in all cases, necessitating a system expansion
• Vehicle electrification further increases peak growth in the Current Policies and Additional Action cases (+3.5 GW)
• Accelerated heat pump adoption in the Net Zero cases drives further peak growth, but the effects are somewhat mitigated in Net Zero B due to the increased hybrid heating
• No Action, Current Policies, and Additional Action remain summer peaking through 2040. Net Zero A becomes winter peaking, while Net Zero B becomes dual peaking
• Flexible loads can play an important role in mitigating peak growth (contributing up to 1 GW in peak reductions by 2040 in Current Policies and Additional Action)

In the past NYSERDA has classified vehicle electrification as a “current policy” because it was a federal policy.  The Trump Administration has made it known that they are going to stop the electric vehicle mandates of the prior Administration, so this removes support of 3.5GW that New York is now going to have to deploy without help.  One of the magic tricks of the NYSERDA plan is using flexible loads to mitigate peak growth.  That consists of assuming that 2.5 GW new large loads will be willing to shut down operations at the whim of low wind and solar resource production.  That is not conducive to manufacturing profitability.

Figure 2: Annual Peak Loads

Figure 3 contains some eye-opening points about the additional actions needed in the electric sector to meet the Climate Act mandates.  NYSERDA mentions that the Pathways Analysis agrees with the CES Biennial Review that the 70% renewable goal cannot be met until 2033.  In a massive under statement they note that “A significant ramp up of deployment will be needed to achieve zero by 2040”.  NYSERDA again mentions a “significant buildout of a diverse set of resources” is required.  Existing hydro and nuclear must be kept online to meet the zero emissions by 2040 mandate.  In a major concession they admit that while “Many aging combustion units retire over the model period. 6 GW are repowered, and the 17 GW fleet is converted to run on Hydrogen by 2040”.  Assuming that hydrogen will be available is sufficient quantities in 2040 is magical thinking as is claiming that the combustion fleet will be smaller due to “availability of other firm resources, like storage and Tier 4 hydro imports”.  If there is such a thing as wishful and magical thinking, then this bullet exemplifies it: “Zero emission resource definition is under development and hydrogen serves as an illustrative resource for firm dispatchable power”.

Figure 3: Electric Sector Capacity (MW) Buildout

It is notable that NYSERDA concedes, without admitting all the ramifications, that the electricity capacity buildouts in their original scenarios are wishful thinking.  I say this because there is another projection included – the “Limited Building Rate Scenario”.  Figure 4 shows the installed capacity projections for it but true to their perfect record of making things difficult for reviewers the colors in the columns for different technologies change.  If you were like me and wondered what the difference in the zero-carbon firm resources (called dispatchable emissions-free resources (DEFR) by everyone else in the state) drop from 17,241 MW to 4,644 MW.  The description notes that:

•            Deployment challenges (including federal impact on attrition and permitting) could lead to a meaningful reduction in renewable build rates

•            While there are still significant additions of renewables, this sensitivity shows a meaningful reduction in solar and wind capacity compared to the core scenario in 2040

There is no admission that among the deployment challenges was an unrealistic schedule and no implementation plan was developed.  They try to save some face by saying that they still build out solar and wind capacity, oblivious to the fact that might not be a good thing.

Environmental Justice organizations have made the peaking power plants in New York City a non-negotiable issue, insisting that all peaking power plants must be shut down as soon as possible.  Even though the presumption of egregious harm from these plants is based on selective choice of metrics, poor understanding of air quality health impacts,  and ignorance of air quality trends, pressure by this special interest constituency resulted in the Build Public Renewables Act of 2023 that mandates shutdown of New York Power Authority peaking power plants by 2030.  This modeling by NYSERDA found that reliability considerations will prevent the shutdown of all the peaking power plants:

•            Zone J repowers 2.2 GW of combustion units in 2035, and overall combustion needs in 2040 are 1.2 GW higher than the core scenario, but still lower than the start of the modeling period

•            While gas generation is 50 TWh lower than 2025, 15 TWh of natural gas generation is needed in 2040 to meet energy needs. Alternately this need could be met via:

•            ~2 GW of new nuclear and likely additional transmission,

• RNG combustion in the power sector, or

•            Some blend of these two resource options (new nuclear and RNG)

The alternatives to the fossil plants are not likely to occur.  2 GW of new nuclear is never going to get developed in New York by 2040 and there isn’t enough renewable natural gas (RNG) to provide the necessary power.

At the end of the description of this slide, there is an admission that the existing schedule is unlikely.  Patane notes that this sensitivity scenario provides a zero-emissions grid in 2045.

Figure 4: Limited build rate sensitivity

Discussion

The results presented in this presentation admit that there are enormous challenges confronting the Hochul Administration’s implementation of the Climate Act.  It is still necessary to read between the lines and understand the implications of some statements, but the handwriting is on the wall.

The presentation concedes that New York State is not on target to meet the 2030 70% renewable goal and probably will not meet it until 2033.  The inclusion of an alternate scenario that keeps fossil-fired units in operation post 2040 is the between the lines” admission that the present strategy is not going to work as envisioned by the authors of the Climate Act. That scenario is supposed to provide a zero-emissions grid by 2045, five years late.

Unfortunately, there are unacknowledged fundamental issues.  There are references to electric system strategies that sound fine in theory but have not been shown to work in practice.  For example, the presentation states that the plan is to use flexible loads to mitigate peak growth.  Assuming that 2.5 GW new large loads will be willing to shut down operations at the whim of low wind and solar resource production is not likely viable.  That is not conducive to manufacturing profitability.

In my opinion, the biggest problem is that the wind, solar, and energy storage approach advocated in the Climate Act requires backup resources for capacity, energy, and ancillary support services not present in wind, solar, and current energy storage systems.  Nuclear power is mentioned as a solution several times but if that is the only viable backup solution, then renewables cannot be implemented without it.  But nuclear can completely replace renewables, eliminating the need for massive backup resource.  Therefore, it would be prudent to pause renewable development until feasibility is proven because nuclear generation may be the only viable path to zero emissions.

There are political ramifications.  The New York Independent System Operator (NYISO) Power Trends 2025 report “underscores the heightened uncertainty of future system conditions and key assumptions such as population and economic growth, installation of behind-the-meter renewable resources, electric vehicle adoption and charging patterns.“  Environmental organizations have responded by claiming that  NYISO’s “conclusions and messaging in Power Trends are not supported by the evidence and perpetuate the false narrative that more gas is needed or is less costly.” Reality bats last and the Pathways Framework is reflecting reality that gas is needed.  Politically however, the environmental zealots will never change their minds and concede that corrections and adjustments are necessary much less admit that the whole endeavor is fatally flawed.  Given that the Climate Act has always been about politics, how this plays out will be fascinating political theater.

Conclusion

New York is at a crossroads  The inevitability of Climate Act implementation viability being a political liability has been acknowledged even by Hochul.  The modeling analysis concedes that the schedule and ambition of the Climate Act is not achievable.  This is the perfect opportunity for politicians to stop a program that even they must realize is not working according to plan.  The Energy Plan could be used to conclude the schedule and the aspirations of the Climate Act need to be reconsidered.  The political implications to that approach are significant.